The defendant is charged [in count __]
with bribery of a juror. The statute defining this offense reads in pertinent
part as follows:

a person is guilty of bribery of a
juror if (he/she) (offers / confers / agrees to confer) upon a juror any benefit
as consideration for the juror's decision or vote.

For you to find the defendant guilty
of this charge, the state must prove the following elements beyond a reasonable
doubt:

Element 1 - Benefit offeredThe first element is that the
defendant (offered / conferred / agreed to confer) a benefit upon <insert
name of target of bribe>. "Benefit"
means monetary advantage, or anything regarded by the beneficiary as a monetary
advantage, including a benefit to any person or entity in whose welfare the
beneficiary is interested.

Element 2 - To jurorThe second element is that at the time
the benefit was (offered / conferred / agreed to be conferred), <insert name
of target of bribe> was then a juror. A "juror"
is any person who has been drawn or summoned to serve or act as a juror in any
court.In this case the state alleges that the
benefit involves <insert alleged benefit>.

Element 3 - As consideration
for voteThe third element is that the benefit
was consideration for the juror's decision or vote. This means that the
defendant must have specifically intended that the benefit offered was in
exchange for the juror's decision or vote. A person acts "intentionally"
with respect to a result when (his/her) conscious objective is to cause such
result. <See
Intent: Specific, Instruction 2.3-1.>

Conclusion

In summary, the state must prove
beyond a reasonable doubt that 1) the defendant (offered / conferred / agreed to
confer) a benefit upon <insert name of target of bribe>, 2) <insert
name of target of bribe> was then a juror, and 3) the defendant and <insert
name of target of bribe> both intended that the benefit would influence the
juror's decision or vote.

If you unanimously find that the state
has proved beyond a reasonable doubt each of the elements of the crime of
bribery of a juror, then you shall find the defendant guilty. On the other
hand, if you unanimously find that the state has failed to prove beyond a
reasonable doubt any of the elements, you shall then find the defendant not
guilty.